Office of the Secretary
Consumer Product Safety Commission
4330 East West Highway, Room 820
Bethesda, MD 20814
Comments regarding Docket No. CPSC-2015-0020
Petition Requesting Rulemaking on Supplemental Mattresses
for Play Yards With Non-Rigid Sides
The National Center for Health Research supports Keeping Babies Safe’s (KBS) petition that requests a ban on supplemental mattresses for play yards with non-rigid sides, which are marketed for use with non-full-size cribs, play yards, portable cribs and play pens. These mattresses present an unreasonable risk of injury or death (suffocation) to infants and toddlers.
We agree with KBS that the supplemental mattresses should be “banned hazardous products because they present an unreasonable risk of injury and death to infants,” and that no consumer product safety standard would protect infants from these risks.
Using Consumer Product Safety Commission data, KBS analyzed deaths and injuries associated with supplemental mattresses between 2000 and 2013 and found 21 incidents. All of the incidents involved a child being wedged between the supplemental mattress and the play yard or portable crib.
To comply with safety standards and avoid suffocation hazards, play yards are made with mattresses that do not exceed 1 1/2 inches and their safety labels state that they should only use the mattress or pad that comes with the product. However, since 3-inch supplemental mattresses (which do not meet the play yard safety standard) are often sold side-by-side with soft-sided play yards, it is not surprising that consumers often assume that they can be used together.
Our mission at the National Center for Health Research is to improve the health and safety of adults and children. Modifying the existing voluntary ASTM standards is not adequate to reduce the unreasonable risk of injury or death that these mattresses pose.
For the above reasons, we urge the CPSC to ban the sale of supplement mattresses.
For additional information, contact Paul Brown at (202) 223-4000 or pb@center4research.org